Corporate Governance

Long Harbour strives to maintain class corporate governance principles that emphasise the stewardship roles played by directors representing the founding shareholders, the responsibility and accountability of executive directors and senior management, professional expertise and integrity. It is, in addition, committed to continuously improve these practices to help foster a high performing corporate culture.

Executive Board

The Executive Board, led by Chief Executive Officer, William Astor, is accountable to all stakeholders, including minority shareholders, and is responsible for setting the medium and long term strategic objectives, overseeing the management performance and maintaining the Group's financial stability.

It is also responsible for providing leadership to, and overseeing the functioning of , the executive directors and senior management team to ensure that they act in the best interests of the Group, to maximise shareholder and investor returns on a sustainable basis.

2

Risk and Compliance Committee

The Executive Board is supported by a Risk & Compliance Committee who adopt and apply corporate governance and management principles across the group. The Committee oversee legal, financial, risk and compliance matters and are responsible for implementing and monitoring policy and procedures (which includes the requirements set by AIFMD regulation as a full-scope AIFM introduced by the FUND sourcebook).

3

Investment Committee

To assist the Executive Board with its entrusted responsibilities, the Investment Committee is delegated the function of reviewing and approving recommendations of all new investment opportunities. The Committee meets as and when required, acting as an independent committee to the Board to enhance the decision making process and any conflict of interest issues. Recommendations are presented to the Investment Committee for approval with a prepared transaction report detailing the key performance indicators, and the business model.

GDPR Privacy Policy

Introduction and background

The purpose of this policy is to outline how Long Harbour Limited has established measures to protect your privacy and information rights.

Your rights

We recognise that you have rights as a ‘data subject’, and that we have an obligation to uphold these.

This privacy notice aims to outline how we maintain these rights. In particular, it outlines:

How we collect and process your information

Why we do this

How you can exercise your rights;

Who to contact in the event you’re unhappy with our performance.

In various circumstances, your rights are as follows:

Right

Explanation

Right to be informed

This encompasses the obligation for us to be transparent in how we collect and use your personal data.

Right of access

You have the right to access your personal data and supplementary information.

Right to rectification

If the information we hold about you is inaccurate or incomplete, you can request that we correct this.

Right to erasure

You can request that we delete or remove personal data where there is no compelling reason for us to continue processing

Right to restrict processing

You have the right to request that we cease processing your data, if:

· you consider it inaccurate or incomplete;

· you object to processing and we are considering whether we still have a legitimate interest to process it.

Right to data portability

· Where you have consented to our processing your data, or where the processing is necessary for us to deliver a contract, you can request a copy of that data be provided to a third party in electronic form.

Right to object

You have the right to object to our processing under certain circumstances. For example, you can object to:

· direct marketing (including profiling); and

· processing for purposes of scientific/historical research and statistics

Rights relating to automated decision making including profiling

· Where we apply automated decision making, we must

· give you information about the processing;

· introduce simple ways for you to request human intervention or challenge a decision;

· carry out regular checks to make sure that our systems are working as intended

Information related to automated decision making is contained later in this notice.

This privacy notice outlines how we are transparent in our processing. Please get in touch with us through the ‘contact details’ section to find out more or to exercise your information rights. There are circumstances in which we will decline your request, but we will explain this clearly to you.

Information we collect

Please find below a summary of the information we process and how we use this to deliver services to you.

Information we collect

Why we collect this

How we process this

Finance

We process this information on our employees to allow us to administer their employment and benefits.

We process this information as one would expect of a responsible employer – to pay salaries, administer benefits, manage our obligations as an employer.

Payroll

Business administration (electronic file and document storage)

Business administration (email)

Human resources

Management agent

Our basis for processing this information is that it is necessary for us to deliver the services that you have contracted to.

We sometimes need to share information with the managing agent for the property.

Transfer of data

We share data with a number of third parties in the course of delivering our services. These are summarised below:

PeopleHR provides us a cloud-based HR management system, to help us administer employee records.

We can share information with other members of the Long Harbour group to support us in day-to-day business administration.

We use the Office 365 suite provided by Microsoft to handle our email and other office automation.

Retention of data

Long Harbour Limited retains information for seven (7) years from our point of last contact. We hold this information to support our legal and regulatory requirements. If you object to this retention, please contact us – details provided in the ‘Contact’ section.

Automated decision making

Long Harbour Limited does not routinely make use of automated decision making or profiling in processing your data.

Securing your information

Long Harbour Limited applies technical and organisational security measures in line with industry good practices such as ISO 27001. Long Harbour Limited has achieved the Cyber Essentials accreditation.

Contact details

We recognise that you may have questions on how we process and/or store your data, or may want to change either the data we hold on you or how we communicate with you in the future.

If you have any questions in respect of this notice, or would like to exercise your rights as a data subject (for example, to correct data or to exercise your right to access):

Long Harbour Limited, as data controller, can be contacted as follows: 33, Wigmore Street, London W1U 1QX

Disclaimer

Introduction and Suitability

This Website and its contents have been approved by Long Harbour Ltd ("Long Harbour") which is Authorised and Regulated by the Financial Conduct Authority ("FCA"). The information contained in this Website relates to both regulated investment, as well as investment funds which are not recognised collective investment schemes for the purposes of the Financial Services and Markets Act 2000 of the United Kingdom (the "Act"). The promotion of the unregulated funds to, and access to this Website by, persons in the United Kingdom is accordingly restricted by law to persons falling within the following definitions:

i. investment professionals having professional experience of participating in unregulated collective investment schemes.

By accessing this Website beyond this point you confirm your status as a professional client or eligible counterparty (as defined in the handbook of rules and guidance issued from time to time by the FCA (the “FCA Rules”) and you warrant as such. Accordingly, the protections afforded to retail clients under the FCA Rules may not be available to you if you become a client of Long Harbour. You are not entitled to sue Long Harbour under sections 71 or 150 ('actions for damages') of the United Kingdom Financial Services and Markets Act 2000. Please consult your legal adviser or visit the FCA’s Website for further explanation. Prospective investors should note that investing with Long Harbour carries a degree of risk and, if you choose to invest in any fund described or referred to in this Website, you may therefore lose some or all of any amount that you choose to invest.

Warranty

This Website and the information contained in it constitutes a financial promotion for the purposes of the Act and FCA Rules. Investment information provided in this Website is believed to be accurate at the date first published and no warranty is given. It may be changed without notice. Any research or analysis used in this Website has been procured by Long Harbour for its own use and may have been acted upon for Long Harbour’s own purposes. Long Harbour reserves the right to grant access or revoke the authority to access, use or reproduce the contents of the Long Harbour internet site at its absolute discretion. While reasonable care is taken to ensure the accuracy, security and confidentiality of information available through the Long Harbour internet site, Long Harbour does not accept responsibility for any consequence of any use of the Long Harbour internet site by any user, authorised or unauthorised. This Website provides an indication of the investment strategy and key terms of the Fund. It must not be construed as investment advice.

Limitation of Liability

Under no circumstances will Long Harbour be held liable for any damages, including, without limitation, direct or indirect, special or incidental losses or expenses arising in connection with the Website or use thereof or the inability by any party to use such Website, or in connection with any failure of performance, error, omission, interruption, defect, delay in operation or transmission, computer virus or line or system failure, even if Long Harbour, or representatives thereof, are advised of the possibility of such damages, losses or expenses.

Law and Variation

This Website is established in England by Long Harbour in accordance with and shall be governed by, and your browsing in and use of this Website shall be deemed acceptance of, the laws of England and Wales. A condition of using this Website is that in the event of any dispute or proceeding you irrevocably submit to the exclusive jurisdiction of the English Courts and waive any objection to proceedings in such courts on the grounds of venue or on the grounds that the proceedings have been brought in an inconvenient forum.

Stewardship Code

Rule 2.2.3 of the FCA’s Conduct of Business Sourcebook requires Long Harbour Ltd to make a disclosure on its website about the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code (the “Code”) or where the firm does not commit to the Code, its alternative investment strategy. The Code is voluntary and sets out a number of principles relating to engagement by investors with UK equity issuers. The firm pursues a range of investment strategies for its clients, those strategies do not involve investment in any UK listed equities. Therefore, whilst the firm is supportive of the objectives that underlie the Code, the investments the firm makes on behalf of its professional clients who are not natural persons are not subject to the UK Corporate Governance Code and the associated Stewardship Code.

Cookie Information

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